ML20134C979

Forwards Insp Rept of License 46-13536-01 on 741126.Two Violations Noted.Violations Will Be Discussed in Separate Correspondence.Related Info Encl

ML20134C979
Person / Time
Issue date:	11/29/1974
From:	Moseley N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Jennifer Davis US ATOMIC ENERGY COMMISSION (AEC)
Shared Package
ML20134C952	List: ML20134C950 ML20134C969 ML20134C971 ML20134C974 ML20134C979 ML20134C984 ML20134C987 ML20134C991
References
FOIA-85-298 NUDOCS 8508190009
Download: ML20134C979 (23)

Text

__

i NOV 2 01974 I,  ; y. . . , . - 1.s l

j

., z .; . 4 . <

i.

I

{ John C. Davis, Daysty Director for Field Operations, Directorate of Regalatory ,

Operations, "--T - - i.ers i

EFBCIAL IMPECTIM - GEN-NUCLEAR SYSTEME, INC., BELLETUE, WANTlacTON 3

(B&ENWELL, SOUTE CAROLINA BURIAL SITE) LICIMBE NO. 46-13536-01 As regmeeted la your amarandum of November 29, 1974, - 1 M is a report '

of en inspestian esaduated by Messrs. F. R. Osian and G. L. Troup en usember 26, 1974.

Our taspection revealed no evidence that radienetivity had migrated from the lie- burial tranch== into the envireas. As a further ev=1==*4== .

of the 11eensee envireammatal sempling program we have samt unter, soil *

,7 ,5 j ,

j

and vegetaties amples to ESL for smalysis.

!

e our inspecties revealed two apparent violations which we plan to oever in separate correspondence.

e,y-,1 ! 'W l

, o c. r . f l l i '

Norman C. Moseley Directar 1

1 l

l i

0500190009 050626

. PDR FOIA

! FLAHARTOS-290 PDR e , , .c . RO II R0 II RO:II 2 . . . . . , , PRGuinn: jag JTSutherland NCHoseley, fh . , _ _ _ , , ,

saee >

11/29/74 11/ /74 g 11/ /74 ,,

Form ASC ll8 (Rev 913) ASGd 0140 8 w as sevenement pe.svise e,peees tesa.eee toe 6

~ . _ - -_.__ _ - ,. _..._ ._-_--.-_ __--____% . , _ , , _ , _ _ . , _ , . . _ . _ _ _ . , , . . _ _ , . , , . . , _ . . ', _ . _ _ _ . _ _ . , _ _ , , , . . , _ . , , . , _ , , , , , . _ _ , _ _ _ _ _ _ . , _ _

1. " '*% UNITED STATES f ,J 3t ATOMIC ENERGY COMMISSION

,* i. l l 4 DIRECTORATE OF REGULATORY OPERATIONS l

afosow ei - suet E eie 230 PE AC MT RE E ST RE E T. NOR T MwE ST , i drag , , , g ATLANTA.cEomGsa 30303 i

John G. Davis, Deputy Director for Field Operations, Directorate of Regulatory Operations, Headquarters SPECIAL INSPECTION - CHEM-NUCLEAR SYSTEMS, INC., BELLEVUE, WASHINGTON (BARhvELL, SOUTH CAROLINA BURIAL SITE) LICENSE No. 46-13536-01 As requested in your memorandum of November 2 , 1974, enclosed in a report

, of an inspection conducted by Messrs. P. R. Guinn and G. L. Troup on November 26, 1974.

Our inspection revealed no evidence that radioactivity had migrated from the licensees burial trenches into the environs. As a further evaluation of the licensee environmental sampling program we have sent water, soil and vegetation samples to HSL for analysis.

l Our inspection revealed two apparent violations which we plan to cover in separate correspondence. -

/ gg, f '

Norman C. Moseley

. Director Transmitted Via Facsir.11.e 11/29/744:00 P.M. tih W

s

UNITED STATES irg '[' )7 l4 i ,

- e i-ATOMIC ENERGY COMMISSION e

• DIREC'NitATr: OF REGULATORY OPERATIONS REGION ll * $ ult E 918

'r steg & = 2 3r) l'E AC H T M E L %i 88 L E T . nom f H wE S T

! AT L A N T A. oL oHL,s

• W303 ,,L,,,,,,, , , , , , , , , , , , , .

l .

a John G. Davis, Deputy Director for Field Operations, Directorate of Regulatory:

Operations, Headquarters SPECIAL INSPECTION - CHEM-NUCLEAR SYSTEMS, INC., BELLEVUE, WASHINGTON

(BARNWELL, SOUTH CAROLINA BURIAL SITE) LICENSE No. 46-13536-01 j

8 As requested in your memorandum of November 2p, 1974, enclosed in a report i

of an inspection conducted by Messrs. P. R. Guinn and G. L. Troup on '

November 26, 1974.

Our inspection revealed no evidence that radioactivity had migrated from the licensees burial trenches into the environs. As a further evaluation of the licensee environmental sampling program we have sent water, soil i and vegetation sampics to HSL for analysis.

l Our inspection revealed two apparent violations which we plan to cover in j separate correspondence. * *

'f t% $

, Norman C. Moseley Director Tran:mitted Via Facsimilo 11/P.9/744:00 P.!!. tlh 4

19 .

_w- - - - - - - - - -- - _L ~-- - '

_x . --

.- ,; DRAFT I b~

. -9

. R0 Rpt. No. 74-1 Inspection Report i

s t Chem-Nuc1 car Systems, Inc., Prepared By:

P. O. Etx 1866 P. R. Guinn, Radiation Date

( Bellevue, Washington 98009 Specialist .

(Barnwell, South Carolina Radiological and Environmental Burial Site) Protection Branch License No. 46-13536-01

. G. L. Troup, Radiation Date i Specialist Radiological and Environmental Protection Branch Inspection Date: November 26, 1974

[ Reviewed By:

J. T. Sutherland, Chief Date Radiological and Environmental j Protection Branch Licensed Activit les Autharized By The State and By The AEC

1. AEC License No. 46-13536-01 authorizes the licensee to receive and process packaged waste byproduct, source and special nuclear material in the amounts specified in the license, in any State in the United States, except. Agreement States, and to dispose of by burial packages containing uranium-235 in accordance with the a=ounts, procedures, and at the designated location specified in the license.

2. State of South Carofina License No. 097 authorizes the licensee to receive process, store for disposal by burial byproduct and source material waste in accordance with the amounts, procedures and at the designated location specificd in the license.

Licensee Activitien The licensee is receiving, possessing, transporting and storing byproduct, source and special nuc1 car natorial wastes in liquid and solid form. Mort of the solid wastec are received and buried in packaged containers, although some internally contaminated pipes and other metal objects are received and buried without containers. Liquid wastes are transported in DOT authorized containers and are buried in metal drums after solidifying with cement.

Spent resins are being transported in DOT authorized containers in semi-liquid form and are buried in special metal containers after de-watering. During the period of October 28, 1971, through November 12, 1974, a total of DRAFT h

s

DRAFT ii RO Rit.i No. 74-1 1 .

d dl 61,586 curies tf byproduct (mostly cobalt 60), 187,796 pounds of source

,(

material (mostly depicted uranium) and 258,326 grams of special nuclear (all uranium-235) material wastes have been received and disposed of by burial in nine burial trenches.

• i q Burial Ground Operations Most solid wastes are being rt.ceived in wooden or cardboard packages and i are taken directly to the trenches for burial. Some amounts of internally 1 contaminated metal pipes and other metal objects are received and buried without containers. Liquid wastes are stored in a designated storage area and as time permits are mixed with cement in 55 gallon drums and after solidification are taken to the trenches and buried. Resins are screened to remove the liquids and placed in metal containers which are then placed 1 in the trenches and buried.

Radiation Control Program

' The licensee is requiring all employees to wear protective clothing, TLD badges and direct rea ling dosimeters. Radiation surveys, including instrument surveys and smear tests, are conducted on all incoming shipcents.

During operations where dusts are encountered, air sampics are taken. Daily instrument surveys are conducted in all work areas, including the trenches in which burials are being made. - Af ter unloading of the trucks, instru ent surveys and s= car tests are conducted insi o the trucks. Contamin: tion surveys are made on each employee when exiting from the work area. Employees are given annual whole body counts and are required to submit quarterly urine samples for analysis. Whole body counts in 1974 for three employees ind ated some uptake of uranium 235, but vore only a fraction of lung burden limits. The only indication of an excessive exposure to any employee was that one employce's film badge result during the fli st calendar quarter of 1974 showed an exposure of 3.3 rem. This was attributed to an exposure to cobalt 60 and was reported to the State of South Carolina.

Control of Releases to the Environment The licensee is controlling releases of radioactivity from the buried wastes l by (1) the burying of solid wastes only and (2) by following burial methods which are designed to prevent the entrance of water into the burial trenches, thereby preventing ml C ration of radioactivity from the trenches. Most of the vasten are buried in wooden or cardboard packages or metal drums. These are placed in the burial trenches which are excavated in a clay soil to a depth of 20 feet (about 20 feet above the water tabic) and are 500 feet in lerCth.

A layer of sand and rock, about three fcet thic!., is pinced in the botto: of each trench for the purpose of co11ceting surface rainwater. The only other treatnent for the trenchen is that during excavation operations clay is r' ed on the sides of the trenches to a thickness of at Icast three feet. Wast l

l DRATT O

D

__._____._.____.S

g

. DRATT J

1 RO Rpt. No. 74-1 .

containers are stacked to a height of 12 feet but no higher than five feet from the top of the trench and then covered with soil. A layer of clay, at least six-fect-thick is placed over the top of the filled trench and then compacted and seeded. Each filled trench is ma*.ked with a permanent granite marker. ,

Environmental Monitoring Program

1. The AEC and State of South Carolina licenses specify that an environment monitoring program shall be conducted, consisting of the following:

i (a) thirty-five well water samples on annual basis (gross alpha, gross beta) except all wells within 1500 feet of trench boundaries shall be sampics on a semi-annual period (b) trench woll water samples prior to burial operations and on a quartc period.

(c) soil samples prior.co burial operations (d) animal and vegetable material sampled " periodically" (e) Water samples from five mu'nicipal water supplies off-site on an annual basis (f) "small number" of air samples to be obtained initially (g) determination of water table configuration in March and September annually (h) water level recorder installed in one well

2. The licensee is conducting an environmental monitoring program which was described by licensee representatives to consist of the followings (a) nine well wate samples on annual basis (gross alpha, gross beta, samma isotopic and tritium): one well water sample semi-annually (b) trench well water samples quarterly (Noter records indicate this is being performed semi-annually review of records revealed no trench well saeples were collected prior to burial).

(c) soilsamplosfromsixlocationsannually(grossbeta,gammaisotopicL veekly saeploc from areas around site (no specific number) (gross be as check for spread of contamination) l DRAFT '

)

l e

b \

g '

yv --

'N DRAFT )

. R0 Rpt. No. 74-1 ~4-1 i

f (d) vegetation samples from six locations annually (gross beta, l

gamma isotopic); no animal samples are collected (c) no municipal water supply samples are collected; the State of Soutt Carolina collects and analyzes the municipal water supply samples and furnishe., results to the licensee n

(f) one continuous air particulate monitor changed weekly and analyzed l (gross beta)

)

(g) water levels in wells logged semi-annually, but not necessarily in March and Septc=ber.

(h) continuous water level indicated with strip chart recorder installs in one well (installed October 1974)

All sampics are collected by licensee personnel. Water, annual soil ans annual vegetation samples are 2nalyzed by Eberline Instrument Corporatic Weekly soil sa=ples and air particulate samples are analyzed on site by the licensee.

3. A review of the environmental monitoring program records indicates a gap in the perforcance of cle 3required saeples between 1970 and 1973 for peripheral well samples and'no data prior to 1973 for other sa.ples (soil, vegetation, aninal material, trench well water). The trench well water sample data ind.':atec that sampics are being collected and analyza semi-annually, not quarterly no stated by the licensee. Also, the wc110 arc ad the site boundary which are not on the ifcensee's property are not being sampled and analyzed nor are animal sampics being collected.

The licensee is not conducting an environmental monitoring program in accordance with the conditions of the license.

4. A review of the availabic sample results for peripheral well water, trench well water, soil and veg tation does not indicate any apparent migration of radioactivity from the burial trenches to the surrounding environs. Exampics of data collected by the licensee to substantiate this ares e

9 I

DRAFT.

i i b

g D  !

[

s...v

. . ..!', I onArr l

u

)

l ,

j

[ RO'Rpt. No. 74-1 ,

1 Well B-18 (peripheral well) gross beta  : 12/70 1.25 E + 1 pCi/1 , ,

3/73 <2.25 2.25 E-2 pCi/1 (reported as <1.00 E+01 d/m/200 ml 2100%

Well B-14 (peripheral well) gross beta 3/73 <2.25 1 2.25 E-2 pCi/1 '

5/74 01 2 3.0 E0 pCi/1 (reported as '<1.00 E+1 d/m/200 al i 100%) ,

Well 2-W-W (trench well) gross beta  : 8/73 0 1 5.5 E0 pCi/1

! 5/74 0 2 3.6 E0 pCi/1 Well 1-E-W (trench well) gross beta  : 8/73 5.7 2 5.7 E0 PCi/1 )

5/74 0 1 3.6 E0 pC1/1 '

Soil sample location fit . 11/74 9/73 Cs-137 1.1 1 0.9 E-01 pCi/g 3.39 2 1.05 E-01 .

Co-60 6.2 2 5.7 E-02 2.19 1 0.85 E-01 !

Bi-214 5.4 2 2.1 E-01 8.06 1 2.53 E-01 i Pb-212 7.8 2 2.7E-01 1.01 1 0.26 EO  !

Vegetation sampic location #4: 11/74 9/73 Cs-137 <1.4 E0 pCi/s 8.19t4.68E-01[

Ph-212 <4.0 EO <1.23 E0 1 Co-60 4.2 2 1.4 EO 9.14 2 3.94 E-01 l r

i l

}

f i

i I

DPMT l

f

. . {'

e

'-----------_C_______________ _ _ _ _ _ _ _ _ _ _ _ _ _

. _ _ .- ~ _ _ _ _ _ _ _ _ _ _ - . _ _ _ _ _ _ _ __ . - _ _ . . - _ _ _ _ . _ _

'. +

g s'"

UNITED STATES l

[

-l h')kl.

St e <

ATOMIC ENERGY COMMISSION DIECTORAT2 0F REGULATORY OPERATIONS

=co.oh n - suit e ein ,

2 K) pF ar.Mi nt e %f m L t f. NOn t MwE 57 ATLANTA.GLORGla )TM ) ,,g, In Reply Refer To:

RO:II:PRG i 74-01 I

Chem-Nuclear Systems, Inc.

l Attn: Mr. Bruce W. Johnson, President P. O. Box 1866 Bellevue, Washington 98009 Gentlemen:

i This refers to the inspection conducted by Messrs. P. R. Guinn and G. L. Troup

• of our Region II office on November 26, 1974, of activities authorized by AIC Byproduct, Source and Special Nuclear Material License No. 46-13536-01 at your i Barnwell, South Carolina burial site, and to the discussions of our findings held by !!essrs. Guinn and Troup with Thomas J. McCord at the conclusion of the inspection.

The inspection was an examination of,the activities conducted under your license as they relate to radiation safety and to compliance with the Commission's rules and regulations and the conditions of your license.

The inspection consisted of selective examination of procedures and i

representative records, interviews with personnel, and observations by the inspe: tor.

During the inspection it was found that certain activities under your license appear to be in violation of AEC requirements. The violctions and references to pertinent requirements are identified in the enclosure to this letter.

This notice is sent to you pursuant to the provisions of Section 2.201 ,

of the AEC's " Rules of Practice," Part 2, Title 10 Code of Federal

[ Regulations. Section 2.201 requires you to submit to this office.

within 20 days of your receipt of this notice, a written statement l or exp11 nation in reply including: (1) corrective steps which have i been taken by you, and the results achieved; (2) corrective steps which will be taken to avoid further violations; and (3) the date when full compliance will be achieved.

l

?

I l l

] l I

I

. 11

> a

! . i

• l s

I i

Chem-Nuclear Systems, Inc. .

You should note that this letter and your reply to this letter will be disclosed to the public by being placed in an AEC Public Document Room.

Should you have any questions concerning this letter, we will be glad to discuss them with you.

Very truly yours, I

R. H. Engelken  !

Director cc: N. C. Moseley, Region II T. J. McCord, Chem-Nuclear a

f l, s w h 4

t

- )

ENCLOSURE

.i i License No. 46-13536-01 e

i i Certain activities under your license appear to be in violation of regulation i requirements as indicated below:

,i Violations considered to be of Category Il severity were as follows:

N A. Condition 1C of the license establishes the requirement that up to

]

] 850 grams of uranium 235 may be possessed at any one time provided j that no single package contains more than 15 grams of uranium 235.

J i Contrary to the above, on numerous occasions since July 1,1973,

packages of wastes for burial have been received which contained j more than 15 grams of uranium 235. Included in this total were -

j 91 packages received during the period of October 18 through 1

October 31, 1974, which cor..ained from 15.1 to 49.0 grams each

]

of uranium 235.

B. Condition 2 of the license references the application dated

) November 18, 1971, and the ammendment dated February 24, 1972, j which establish the requirement in Appendix 6 that the environ-1 mental monitoring program shall include sampling and analysis i of water, soil, vegetation and animal material at established

} frequencies and locations.

? .

Contrary to the above, the environ ental monitoring program being j conducted is not of the prescribed scope in that the required number [

i of wells and municipal water supplies are not being sampled and no j animal material sampling has been conducted. j 4 F j L

[

t I i i

! i i, ,

i i

t i

1 J

g a l 1

s e, , .

~ .

/ -

+ / 7 ff l l

i I

l '

i  :

l i

k Ph ASSIST DEFECTION FOR REGION V CHEM-NUCLEAR SYSTEMS, INC. , BELLEVUE, WASHINGTOW  !

l (B.M. 8.C., BURIAL SITE) LICENSE NO. 46-13536-01 (TERU AM(ENDMENT NO. 5 ;l

D&S'E3 mkt 20,1973) l

' i General Informatise i

j Ga Eevedet 26, 1974, an announced inspection was made by P. R. Quinn and G. L. Troup, Region II, of the licensee's activities at the Barewell, Seeth Carolina burial site. This inspection was made primarily for the , , , ,

purpose of determinias if the buried materials had migrated into the agt "x .

as requested by J. G. Davis,10 Headquarters, in his memorandum dated , , - 1 nopember 25, 1974. This part of the inspection was covered in the b.-

i inspectima report asiled to 30 Headquarters on November 27, 1974 .

routine inspection was conducted which revealed two apparent vio tions.

These were covered in the draft enforcement letter seat to ReBion V on I

%r 4,1974, for dispatch to the licensee.

Althoud the State of South Carolina was notified of the proposed inspection they did met beve a representative present during the inspectic.n.

Perseas Contacted I l, Ibouns J. McCord, Manager, Nuclear Operations (In charge of the Barnwall site) '

R. Posisk, Manager Industrial and Nuclear Safety i H. 1. Oakley, Operations Manager Astivities Under The License _ j' 1

The 3 to collect radioactive wastes throughout the j burial at the Barnwall, South Carolina burial site. I I i

l transported to the sita in licensee trucks. Most so received in cardboard or wooden besse which are j!

treaches and buried. Some internally eentaminated .

metal pipes are alas baias buried. Liquid wastes are being trantported ,

in D0f approved eestainers which are mixed with cement la 55 gallas dras i

!) '

sad sham buried. Spent resins are being transported in DOT approved con- ,;

tainers and are buried in metal containers af ter the resin.have been screened to remove the emesse, 44.

l)

All bertals of byproduct and source asterial wastes have been conducted ender Stata of South Carolina License No. 097. Since July 1, 1973, i burial of special moelear materials have been conducted under the AEC license.

W .

. . i

w

• g, -

M Et M ,

As records showed that since October 28, 1971, a of byproduct unterial (asstly cobalt 60),

asterials (mostly depleted uranit.m) and unsleer material (all uranima 235) wastes been sad buried at the Barunroll, South Carolina site.

l (emydas ed 1(m===== records are attashed to the Regios II inspection  ;'

l sayses),b en seamage, 30 to 35 truck leads of waste (all types) arm betag sneenved and week. Qmestioning of lisensee perseensi and an l j

aumminaties of records pertaining to special suelear meterial receipts l eheued that individual peakages of unstes ecstained up to 49 grues of i l I usesium 235 skila the total amount contained in all packages in each Aipment aestained up to 350 grams. (Coedition 1C ef the lisense iI

! atates that as single package may contain more than 15 grams of  ;

}

seanien 135) As audit of reeords for the period of October 18 f t W Osteber 31, 1974, showed that a total of 427 packages of i urami= 215 unstes (14 truck leads) had been received and of this

' estal 91 peehages esetained from 15.1 to 49 grams of uranium 235.

- Se total amount of uranium 235 sostainad la each of the 14 truck lands ranged from 292 to 350 grams.

Durial prosedures N .

En apparent ebengas have been made in the burial operations noted M' i during the last inspection. h burial methods are designed to see-saia the asterials within the burial trenches thereby preventing utgratism of the materials into the estviroes. The treaches are sheet 500 feet laes sad 20 feet deep and are excavata: in a clay esil.

l During the burial operations elay is placed over the top of the tremebas, ee w ted and then seeded. (The attached espy of the

]

inspecties repert, dated December 4,1974, which was submitted to  ;

R0 Enadquarters gives further details of the burial operatioes) j madiariae serveys i:

M Istarviews with lieanees personnel revealed that radiation are being j.

4 anda as follows:

1. surveys, imeluding readings with radiation survey to nd w a4. y f, wipe tests are made on all incoming shipman s. Irenches. -

that only occasional low level couramination '

b been found on treaches and shipments. If .

\

-gamma er 220 dpm alpha; decent ==ination is as on shipments smet n.st exceed 200 mr/hr om j; the sur sud 10 ar/hr at 3 feet. m reading in the cab of l the treeks smet met exceed 2 ur/hr. ll ;

i L

\

i I k

1 I

2.

s are taken in all areas of the burial site l site office. l

!1

3. readings are taken around all filled trenches. ' !

! re made on the treaches which are being filled) l l

4. Liseasee eeenS. drivere make surveys of asch package of waste as  ; i l it is leaded into the truck. If readings exceed those shown in i

' item M the peekages are rejected. i

5. Air easyles are taken at random intervals in various work areas.

(The records show no significant results to data)  ;

I l Perocenal hoitorias i

! The 11eassees personnel monitoring program involves the following: ,

l 1. All workare in the burial trench area and truck drivers are required

- te wear TLD's and direct reading dosimeters. Eberlina is providing the TLD's em a monthly service basis. A review of these results showed that six employees had received 3150 area to 7020 aren doe [s k. g,4n to the whole body during 1973 but only one had exceeded 3 rem durtag any calendar quarter. Employee Boyle.s had received 3370 aren during' ~

(

the 1st calendar quarter and a total of 7020 mram for the year. This -

was reported to the State of South Carolina who conducted an investiga-tion. Boyles had assisted in unloading and burying some irradiated reactor componenta. A Form AEC-4 had been established for all smyloyees. Through October 31, 1974, no employee had received in '

excese of 3 rem during any calendar quarter although one employeejYo(

@ had received a total accumulated dose to the whole body of 4350 mrom.

2. Urine samples are collected from all burial site employees each calendar quarter and sent to Eberline for analysis. The highest results noted to date was up to 25 dps/ sample which is considered :L 2 W to indicate little or no uptaka of materials.

3. Each burial site employee is whole body counted by Helgeson once a year. The results for eight employees counted on March 2, 1973, map ".. The results for 13 employees counted on May 23, 1974, ,

rv four esployees with results indicating some lov level up-sehe ad usanium 235. These results were 60, 69, 70 and 78 micrograms erg,g ,pgreast on a permissiable lung burden. (Approximately)

4. Pereoamel are required to monitor themselves for contamination each time exit is made from the burial site area. Only slight amounts of i contamination have been detected on employees to date. l l

I l

i l

I l ,

e

P Files 6.

, j . . , .: .

' Envi. _

-5 MusiWies This program is discussed os pages 3 and 4 of the attached inspection report which was embaitted to 30 Beadquarters on November 27, 1974. It was acted that the licenses has act been conducting an environmental sampling program of the required scope as established in Appendix 6 of the license.

Manaamment Boview At the conclusion of the inspection the two apparent violations were dis-cussed with McCord. He said they would be corrected.

P. R. Quinn Radiation Specialist

~r i

i

)

i RO:1 RO:II RO:II fterlar d.

.w.....* PRGu n:pw ut "'" ..._ .^

m.ts h 12/ /74 . . .

2//f/74 --I

f;;

. l

! Poems ABC 3te (Rev. >SS) AsCM 9240

• w. a.eeveme neet penevise speeemssete.ene.see b

k g

s .- g i .

Inspection Notes / Record Copy Written procedures have also been established 4 6f covering ,

all aspects of the licensed activities. The procedures cover all uses of licensed materials and also contain instructions to be followed during emergency conditions. Schultze has y

several years experience in the use of radioactive material

including experience with the Union Carbide Corporation and as%tateofSouthCarolinaCoordinatorofAtomicEnergyand

~

Industrial Development Programs. He h from the University of North .:arolina. yJE g Ph.

a IsoD.has in Chemistry several years experience in t!.e handling of radioactive material including experience in Hanford, Washington, the General Electric Company's Vallecitos Atomic Laboratory and with Nuclear gngineering Company at the Morehead, Kentucky burial site.

8. Schultze stated that chem-Nuclear, Inc. , holds the following Agreement State licenses which authorize the pickup and storage of radioactive vaste: .

Oregon - License No. ORE-0219-1 South Carolina - License No. 097 Washington - License No. WN-1051-1 (The South Carolina license authorizes possession of l waste containing up to 5,000 curies of byproduct material, l 60,000 pounds of source material and 350 grass of SNM material) l .

III. Receipts and Transfers

9. The licensee's records of receipts and transfers were reviewed to determine the kinds and amounts of licensed materials that had been possessed under the license. T.ie licensee's records showed that the following quantities of cobalt 60 resins had been picked up at the Norfolk Naval Base in Norfolk, Virginia, and transferred to the Tennessee Nuclear Specialists storage site in Jonesboro, Tennessee.

9/29/70 - 100 me cobalt 60 resins 9/24/70 - 19.5 me cobalt 60 resins 9/22/70 - 32.7 me cobalt 60 resins 10/23/70 - 18.6 curies cobalt 60 resins ,

9/4/70 - 105 me cobalt 60 resins .

10/1/70 - 57.7 me cobalt 60 resins 10/6/70 - 411 ne cobalt 60 resins 10/8/70 - 72.8 me cobalt 60 resins 10/13/70 - 3.0 se cobalt 60 resins 10/15/70 - 31.'1 curies cobalt 60 resins 4

t 20 s

--r- - - ---- - -

s .. g

~

I Inspection Notes / Record Copy a 10/20/70 - 4.6 curies cobalt 60 resins .

10/27/70-78.5 curies cobalt 60 resins Chem-Nuclear, Inc. took possession of these resins at the Norfolk .

Naval Shipyard and then shipped them by cmmercial carrier to Jonesboro, Tennessee, for storage. The times tha* the licensee possessed the cobalt 60 resins at the Norfolk Naval Shipyard were subject to AEC jurisdiction.

4

10. The licensee's records show that approximately 30,457 pounds of waste materials containing approximately 4.2 curies total of byproduct materials had been picked up frau various custaners throughout the southeastern United States. This material is being held in storage at the Chem-Nuclear sl~orage site in Barnwell, South Carolina. About 1500 millicuries of this byproduct material waste 1 . material were picked up at the Union Carbide facility in Charleston, West Virginia. During the time that this material fran Union Carbide was in the possession of Che=-Nuclear in West Virginia, a non-Agreement State, this was subject to AEC jurisdiction.

11. The licensee's records of receipts and transfers of special nuclear

material showed that the following quantities of special nuclear

material had been received to date and consisted entirely of unrecoverable uranium oxide containing U-235

Facility AmountMW Date  !

] & Address Descrir> tion (arans) Received  ;

I Southern Space, Inc. two 55-gallon drums 220 11/2/70 N. Charleston, S.C.

(laundry facility) l Interstate Industrial two SS-gallon drums 174 6/15/70 Unifom N. Charleston, S.C.

(laundry facility)

Westinghouse Electric baled waste 348 5/20/70

Corp. ,

Columbia, S.C.

. 343 5/27/70

, 347.6 ,

6/2/70 349.1 6/4/70 164.7 6/16/70 154 10/20/70 I

i g _.

e a e a

l Inspection Notes / Record Copy Facility Description Amount //17f Date

& Address (grams) Received Westinghouse Electric 52 bales 193 10/20/70 Corp.

Coltenbia , S. C.

Westinghouse Electric 7 bales 5[ 10/21/70 Corp.

Coltsabia, S. C.

Westinghouse Electric 74 bales 294 10/27/70 Corp.

Columbia , S. C.

Westinghouse Electric 8 bales 80 3 anse- 11/3/70 Corp.

Coltenbia, S. C.

Westinghouse Electric 5 bales 49 gzamer 11/3/70 Corp.

Columbia , S. C.

Schultze stated that SNM wastes are transported from the customer facilitier to Barnwell, South Carolina for temporary storage.

He stated that these wastes are then transported in a Chem-Nuclear truck with a Chem.-Nuclear employee as the driver of the truck,to the Nuclear Fuer(IYdIY1on in West Valley, New York for burial.

He stated that e(ery ef fort had been made to see that the 350 gran limit established for SNM waste materials in the South Carolina license had not been exceeded. He stated that at no time had the amount of SNM waste materials exceeded the 350 grams. Schultze stated that in his opinion possession of the SNM waste materials at the Barnwell site and during transportation of the materials to West Valley, New York, a604e&ut48.was under the provisions of the South Carolina license. (As will be shown in the following paragraph the shipments of SNM waste materials fran Barnwell, South Carolina to West Valley, New York, are subject to AEC jurisdiction while

- it was being transported in the Chem-Nuclear truck with a Chan-Nuclear maployee as the driver while the material was en route through the non-Agreement States of Virginia, West Virginia, Maryland, ard Pennsylvania).

a

, v e

j .

l I-Inspectior. Notes / Record Copy i

12. A review of the licensee's records showed that during the times that the licensee possessed licensed materials under AIC jurisdiction, the possession limits under the license for byproduct materials had ,

not been exceeded. fiowever, the licensce's records showed that on ,

seven separate occasions in 1970 more than 200 grams of SE waste materials had been possessed by the licensee in non-Agreement States and thereby subject to the possession limits of the ABC license of 200 grams. It us determined that the following shipnents had been possessed b/ the licensee in a Chem-Nuclear truck with a Chem-Nuclear employee as the driver while Sm waste material containing unrecoverable U-235 was being transported through the non-Agreement States of Virginia, West Virginia, Maryland, and Pennsylvania.

5 20/70 - 348 grams U-235 5 27/70 - 343 grams U-235 .

6 2fl0 - 347.6 grams U-235 l 6/4/70 - 349.1 grams U-235 6/16/70 - 164.7 Frams U-235 10/20/70 - 347 grams U-235 10/27/70 - 348 grams U-235 ,

11/3/70 - 349 grams'U-235 l 6/15/70 - 174 grams U-235 Seven of the above shipnents exceed the possession limit of the I license as established in paragraph 1 which states that the licensee shall not possess at ary one time more than 200 grams of SNH.

IV. Facilities and Ectiment ,

13 Schultze and Powers were questioned regarding the Chem-Nuclear facilities. Schultze said that Chem-Nuclear has office facilities located in Prosser, Washington, and in Columbia, South Carolina, while they have storage facilities located in Arlington, Oregon, and Barnwell, Scuth Carolina. Ad inistrative offices are located in Portland, Oregon, but according to Schultze, are expected to be moved to Wenatchee, Washington, in the near future. The Barnwell,  !

South Carolina, storage area is 1ccated'in the County of Barnwell, South Carolina, approximately one mile IM of the town of Snelling and occupies the southern corner of a track of land referred to as the laura Moore track. Chem-Nuclear also has the adjacent tract of e

f 6

h 0

, w e

'Inspectica Notes / Record Copy land referred to as the W. W. Moore property. Approximately 250 acres of land are available for use by Chem-Nuclear Services, Inc.

The Barnwell storage site is surrcunded by a chain-link fence topped with three strands of barbed wire. Inside this area are two separate fenced-in areas which also are surrounded by a six-foot .

high chain link fence topped with barbed wire. These two areas inside the larger areas are referred to as storage compounds No.1 and No. 2. The storage compound No.1 is used for storage of S?H radioactive waste. Iceked entranco gates are used to secure the area and the keys to the entrance are controlled by Powers. Schultze and Powers stated that appropriate warning signs are posted around tbs fenced-in area.

14. Ample supplies of coveralls, shoecovers, gloves, etc. are available for use by personnel. Several radiation detection instruments are on hand including beta-gn=ma and alpha detection equip,ent. Most of this equipment has been procured from Eberline. Schultze stated that three CT-69 shipping casks are available for use. He stated that each of these casks weighs approximately 46,000 pounds while empty. He stated that to date, these casks have been used only for shipping the cobalt 60 resins frcn the Norfolk Naval Shipyard to the storage site at Jonesboro, Tennessee.

V. Personnel Moniterine and Radiation Surveys 15 A personnel monitoring prcgram is being conducted by means of direct reading dosimeters with ranges from 0 to 200 mr and film badEes. The dosimeters are being read daily while the film badges are changed at monthly intervals. Film badge services are supplied by the U. S. Testing Company. In response to questions regarding personnel exposures, Schultze and Pcwers stated that personnel exposure records are being maintained by Famer but Powers also keeps a record of these results at the Barnwell, South Carolina Site. These records were not available for review at the time

• of the inspection but both Schultze and Powers stated that to the best of their knowledge none of the exposures have ever exceeded a total exposure of 500 mics during any one month period (Fowers said this exposure occurred at the Barnwell storage site during the last, quarter) and that no "off scale" dosimeter readings have been noted to date. Schultze stated that none of the personnel exposure totals have ever exceeded the li.aits in 10 CFR 20.

e 6

9 O

O g

e Inspection Notes / Record Copy 16. Radiation surveys are being conducted and records of results are being maintained. Powers is conducting most of these radiation surveys and has recorded results in a logbook and

• on the appropriate shipping papers for each shipment of radio-active waste material. The records were reviewed and it was noted that radiation measurements had been made on each shipping container at a distance of one meter and on the surface. It was noted, for example, that on the shipments of cobalt 60 resins to the Jonesboro storage site thct a maximus radiation level of 17 mr/hr had been noted on the aurface of the shipping cask and that the maximus radiation level noted at a distance of one meter was 6~mr/hr. Powers stated that he wipe tests the trucks prior to release of the trucks to transport materials to storage sites or burial grounds and he also took smears and did instrument surveys on empty containers and trucks when returned to the Barnwell site. In response to a question regarding the radiation surveys on the shipping cask for the cobalt 60 resins, Powers stated that these radiation surveys have been made by U. S. Navy personnel at the Norfcik Nava,1 Shipyard but that he had checked ,

results on several ocessions and that Navy personnel are making good radiation surveys on these shipping casks. Powers stated that also he had conducted numerous radiation surveys at the storage site at Barnwell, S.C., and the radiation levels outside the fence around the storage site in unrestricted areas had not exceeded 0.2 mr/hr. Schultze stated that no shipments of radio-active waste will be made if the radiation levels fras the shipping containers exeecd 10 mr/hr at one meter or 200 mr/hr *

- on the surface of the shipping container.

VI . Postinr and Labeling

17. In response to questiens regarding posting and labeling of storage areas, storage containers, and shipping containers, Schultze and Powers stated that efforts had been cade to ca: ply with all AEC requirements and all ICC requirements. Powers stated that all shipping containers contain labels with the conventional radiation caution symbol, with " Caution Radioactive Materials," and information showing the kinds and quantities of radioactive materials. The various ICC labeling requirenents were discussed with Schultze and Powers.

e D

• p*

• 6 - Oh **

• g e b

I k

i .

I j Inspection Notes / Record Copy - 12 -

1 Each specific requirement was pointed out and both Schultze and Powers indicated that they had fully complied with the requirements, f, VII. Review with Licensee Manamement i

l

18. At 9:00 a.m. on December 3, 1970, the inspuetion results were e e a o  :

J Frederick P. Ieierle, General Manager, Cham-Nuclear, Inc.

j Willian D. Johnson, Manager, Special Projects, Chan-Nuclear, Inc.

l Henry C. Schultze, Vice President, and Manager, Eastern Operations, Cham-Nuclear, Inc.

j Clifford F. Powers, Manager, Barnwell Site, Cham-Nuclear, Inc.

Heyward C. Shealy, Director, Radiological Health, State of l South Carolina l

~

Paul R. Guinn, Region II, Division of Compliance 1

• l Guinn opened the meeting by stating that the inspection on November 19, 1970 had been limited to the activities conducted l

under AEC jurisdiction. Activities which had been conducted j under AEC jurisdiction included the activities involving waste pickup at the Union Carbide Corporation, Charleston, West Virginia,,

which is a non-Agreement State, the period of time in which the cobalt 60 resins were in possession of Chen-Nuclear, Inc. , dad */E4 j Norfolk Naval Shipyard (, and the period of time during which the i SNM waste materials were in the Chem-Nuclear, Inc. , truck with the Chen-Nuclear, Inc. , driver during transport through non-Agreement f States to burial sites at West Valley, New York. At this point l

1 Schultze stated that it had been his opinion that the shipments j of SNM waste materialf to West Valley, New York had been conducted under the South Carolina license. He was informed that since the SNM materials had been possessed in a Chem-Nuclear, Inc., truck with a Chem-Nuclear employee as the driver and since the truck i

had been driven through the non-Agreement States of Virginia,

{

West Virginia, Maryland, and Pennelyvania, that the time these i

materials were possessed in these non-Agreement States t W t the

! AEC had jurisdiction and all the requirements of the AEC license

! . would apply. The group was then informed that the only itas of 4

i .

I -

i 4

1 e

i

• i .

4

--"--+r e-*=+mwgV-f-p-*-wed -'--e+e- ----mes-- tt----; "Weg- y y , gem-pre-en g ererg- wm-g-

,, g.

InspectionNotes/RecordCopy -13 noncompliance noted during the inspection concerned License Condition No. I which states that no more than 200 grams of Sm may be possessed at any one time whereas the Chem-Nuclear transfer records showed that on seven separate occasions more than 200 grams of Sm have been .

possessed in waste material while being transported through the non-Agreement States of Virginia, West Virginia, Maryland, and Pennsylvania, in a Chan-Nuclear, Inc. truck and with a Chan-Nuclear, Inc. employee as the driver. It was explained that if the shipments had been made by ccamercial carrier or if the shipents had been limited to 200 grams or less, that the iten of noncompliance could have been avoided. .

Schultze again stated that it had been his impression that the shi;snents were being made under the South Carolina license under tems of the reciprocity agreements of the AEC and Agreement States.

After further discussion, both Schultze and Beierle acknowledged the itan of noncompliance and stated that a request would be submitted to DIL innediately for an amendc.ent to the license to increase the possession limit to 350 grams for Sm. They also stated that no further shipnents above the 200 gram limit would be made until such time as the increased possession limit is authorized. In closing, Schultze stated that he and Beierle would be at AEC Headquarters on Wednesday, December 9,1970, and that this matter pertaining to the item of nonecapliance would be discussed further with DiL at this time.

Beierle stated that his new mailing address is Box 918, Wenatchee, Washington 98801.

e 4

k l e s .

CilEM-NUCLEAR SERVICES, INC. lGREATCOLUMBIACORPORATION I i i

ORGA*llZATIONAL CllART CHEli-dUCLEAR SERVICES, INC.

APPROVED - - - l 0FFICE OF PRESIDENT ~ ~~

[BOARDOFDIRECTORS JUNE - 1970 R. F. TAPLETT t

' l . --_

l- 1 I

1 I 0FFICE OF RADIATION  : GENERAL MANAGER RADIATION SdFETY

~~ ~ ~ ~~~ '~ ~

PROTECTION F. P. BElERLE -

COMMITTEE -

l 2 '3 g ._ - . _ - . .

I  !

WESTERN OPERATIONS DIVISION l EASTERN OPERATION

' ,.lGR. FARMER D.V.M.

DIVISION MANAGER H. C. SCHULTZE Ph.D.

HNIAGER SPECIAL PROJECTS DIVISION l V. D. JOHNSON MANAGER h

1- .

~

P

1. Chem-Nucigar Services , Inc. , is a wholly owned subsidiary of the Great Columbia Corporation.

- - 2. Chief Radiation Protection Of ficer, Dr. G. R. Farmer; Assistant RPO, W. D. Johnson; Assistant RPO,

- Cli f ford F. Powers.

3 Radiation Safety Committee composed of President, General Manager, Eastern Division Manager, Western Division Manager, and Chief Radiation Protection Of ficer.

4. Special Projects Division operates as assigned in either Division. (Presently assigned to Vestern Operations Division)

/

s o .

~

- - _ _ _ _